Date: 4/6/99 1:42 PM
Subject: S7-5-99
Sirs,
The proposed amendments to Rule 15c2-11 appear to contain provisions
which will clearly hurt legitimate companies such as ours (i.e. we
qualify for NASDAQ in all ways except stock price, and the artificial
event of a reverse split can accomplish this without any change in our
operations nor Balance Sheet--hardly a pragmatic rule given the negative
effect of a reverse split; we are a full reporting firm which should be
differentiated from non-reporting Bulletin Board firms). Of greater
impact is the obvious result of applying these anti-fraud conditions on
market makers of all Bulletin Board stocks: the legitimate market
makers who are left will be forced to widen spreads and help accelerate
rapid swings in stocks and the more prevalent market makers who are
left--namely the less-reputable firms--will make the markets both
illiquid and immoral. Please remove full reporting companies from the
onerous market-maker amendments.
Sincerely,
David McCaffrey, CEO
Global Maintech, Inc. (GLBM)